I. Introduction
This indictment is submitted on behalf of victims and affected parties to allege serious international crimes committed by the Chinese Communist Party (CCP), the People’s Liberation Army (PLA), and related state agencies. These crimes encompass mass murder, war crimes, crimes against humanity, violations of international treaties, and customary international law, including acts that caused mass civilian suffering and death, biological weapons development and use, suppression of fundamental freedoms, and medical neglect.
II. Jurisdiction
This draft asserts jurisdiction based on:
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The principle of universal jurisdiction over grave breaches of international humanitarian law and crimes against humanity;
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The applicability of customary international law and treaties ratified by China at the times of the alleged crimes, including:
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Hague Conventions (1899, 1907)
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Geneva Protocol (1925)
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United Nations Charter (1945)
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Nuremberg Principles (1945)
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Biological Weapons Convention (1984)
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International Covenant on Civil and Political Rights (ICCPR, 1998 ratification)
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International Health Regulations (2005)
III. Parties
Plaintiff: Victims and affected families of the CCP’s actions, including but not limited to victims of COVID-19, forced famine, war crimes, and political repression.
Defendants: The Chinese Communist Party, the People’s Liberation Army, and affiliated government entities responsible for directing and executing the alleged crimes.
IV. Statement of Facts and Allegations
1. Mass Murder of Gu Shunzhang’s Family (1931)
The CCP leadership, under directive of senior officials including Zhou Enlai, orchestrated the capture and execution of Gu Shunzhang’s entire family — approximately 30 individuals, including women and children — employing brutal methods such as dismemberment, burning, and disposal of bodies in wells. Internal CCP documents state: “全部就地解决，女人孩子一个不留” (“All to be eliminated on site, leaving no women or children alive.”)
Legal Implication: Violates the Hague Conventions’ protections for civilians (Hague IV, Articles 46, 50) and Nuremberg Principles on crimes against humanity.
2. War Crimes During Anti-Japanese War (1937–1945)
While publicly resisting Japanese invasion, CCP forces engaged in military strategies that preserved their strength rather than actively fighting the enemy, preparing for future civil conflict. After Japan’s surrender, CCP forces appropriated biological warfare facilities of Unit 731, protecting Japanese war criminals and integrating them into CCP research. CCP records note these individuals as “有用，应予保护使用” (“useful, should be protected and utilized”).
Legal Implication: Violations of Hague Convention IV (Articles 23, 46), Tokyo Charter, and customary law prohibiting harboring war criminals and misuse of biological weapons.
3. Siege of Changchun (1948)
CCP forces besieged the city of Changchun for five months, cutting off all supply routes, resulting in starvation and death of an estimated hundreds of thousands of civilians. The siege was praised in CCP military literature as a “成功的人民战争范例” (“successful example of people’s war”).
Legal Implication: Violation of customary law prohibiting starvation of civilians (Hague Regulations, Article 50), and Nuremberg Principles on crimes against humanity.
4. Forced Grain Requisition in Sichuan (1950s)
Under Deng Xiaoping’s administration, massive grain requisition was enforced, forcibly seizing food from local farmers, exacerbating hunger and suffering. Such acts amounted to pillage prohibited by the Hague Convention IV (Article 28).
5. The Great Chinese Famine (1958–1962)
Policies including the Great Leap Forward resulted in catastrophic famine causing tens of millions of deaths. Mao Zedong’s statement, “人是要死人的，不死是不行的” (“People must die; it cannot be avoided.”) at the 1959 Lushan Conference reflects state awareness of human cost.
Legal Implication: Constitutes crimes against humanity (Nuremberg Principle VI(b)), including extermination by deliberate policy.
6. Biological Weapons Development and Use
CCP engaged in the development of biological weapons, integrating former Japanese Unit 731 scientists and maintaining active research, in violation of the 1925 Geneva Protocol (ratified 1952) and 1972 Biological Weapons Convention (ratified 1984). CCP military media acknowledge live-agent drills to test defense capabilities.
7. COVID-19 Pandemic: Origin Concealment and Obstruction
COVID-19 emerged in Wuhan in late 2019. CCP and PLA possessed early knowledge of human-to-human transmission but delayed notification to the WHO and global community, violating International Health Regulations (2005). Independent researchers (such as Dr. Li-Meng Yan) allege the virus originated from military lab modification of bat coronaviruses related to the Zhoushan bat virus, supported by CCP's official papers and public reporting. CCP’s concealment and obstruction contributed to the global spread and loss of life.
- COVID-19 emerged in Wuhan, China, in late 2019 and rapidly became a global pandemic.
- The Defendant had knowledge of the virus's existence and human-to-human transmissibility by 1 Jan 2020, but delayed public disclosure and international notification, violating international health obligations.
- On January 18 and 19, 2020, Lude Media publicly alleged that COVID-19 was capable of human-to-human transmission and originated from a military laboratory; the Chinese government officially acknowledged human-to-human transmission only on January 20, 2020, one day after these claims began circulating in Chinese-language media.
路德社的的老推特账号 https://x.com/ding_gang 于2020年1月18日发了附图所示信息“独家重磅给路德爆料：武汉的类SARS冠状病毒就是来源于中共军方2018年从舟山蝙蝠身上发现并分离的新型冠状病毒。如图改病毒序列可以在美国国立卫生研究院的基因数据库找到（NIH的GenBank），由南京军区军事医学科学研究所递交。并且通过技术故意更改舟山蝙蝠病毒，适于人类传播的新病毒”至今未恢复。另一个推特号是https://x.com/ding_gang02 也未被恢复。路德社的Substack号是 @路德社 。
- CPA Jim
Read on Substack- Evidence suggests that the CCP and PLA controlled and restricted access to critical data, hampering global response efforts.
- Independent researchers, including Dr. Li-Meng Yan and the outlet Lude Media, have alleged that COVID-19 originated from genetic modification of bat coronaviruses, specifically related to the Zhoushan bat virus, potentially within a military laboratory setting and was released in a military drill or actual combat training.
- Official records from the CCP, including documents authored by CCP officials and PLA officers, contain information that supports the possibility of such military involvement.
- The Defendant’s actions and omissions contributed to the uncontrolled spread of COVID-19
8. Suppression of News, Free Speech, and Network Control
Since the early 2000s, CCP has implemented censorship programs (“Golden Shield Project,” “Great Firewall”) systematically suppressing dissent, restricting information flow, and monopolizing media channels, violating ICCPR Articles 19 and 21 on freedom of expression and assembly. This censorship severely obstructs domestic and international awareness, accountability, and economic fairness.
9. Imprisonment and Medical Neglect of Liu Xiaobo
Liu Xiaobo, Nobel Peace Laureate, was imprisoned for peaceful activism. CCP denied medical treatment leading to his death in custody. Official CCP media describe his death as “自然死亡” (“natural death”), despite evidence of medical neglect. Violates UN Convention Against Torture (Articles 1,2), ICCPR Articles 6 and 7.
10. Cover-up and Repression after 2008 Sichuan Earthquake
CCP authorities obstructed investigation into substandard “tofu-dreg” school construction responsible for thousands of child deaths, suppressed protests, and censored coverage. Official internal directives forbid family gatherings and information dissemination to “防止敌对势力炒作” (“prevent hostile forces from exploiting”). Violates ICCPR Articles 6 and 19.
11. Coercive Family Planning Policies
Implementation of forced abortions and sterilizations under the one-child policy constitute grave violations of bodily autonomy and reproductive rights, infringing ICCPR Articles 7 and 17, and CEDAW Article 16.
V. Legal Counts Summary
| Crime | Legal Basis | Applicable Treaty / Principle |
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| Mass murder of civilians | Crimes against humanity | Nuremberg Principles, Hague Conventions |
| War crimes including siege tactics | War crimes | Hague Conventions, Tokyo Charter |
| Crimes against humanity (famine) | Crimes against humanity | Nuremberg Principles |
| Biological weapons development | Prohibition of biological weapons | Geneva Protocol (1925), BWC (1984) |
| Violation of International Health Regulations | Breach of international health obligations | IHR (2005) |
| Suppression of free speech and censorship | Human rights violations | ICCPR Articles 19, 21 |
| Torture and medical neglect | Prohibition of torture | UNCAT, ICCPR Articles 6, 7 |
| Repression and censorship after disaster | Human rights violations | ICCPR Articles 6, 19 |
| Forced family planning | Violation of bodily autonomy | ICCPR, CEDAW |
VI. Relief Requested
Plaintiff respectfully requests a tribunal to:
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Initiate a full and impartial investigation into the above allegations;
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Order the production of relevant documents and evidence by the CCP and affiliated bodies;
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Hold accountable responsible individuals and entities through criminal prosecution;
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Award reparations to victims and families;
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Recommend international sanctions and mechanisms to prevent recurrence;
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Facilitate independent monitoring of CCP compliance with international law.
